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Success Fee Model Legal Alignment

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#LegalFees #SuccessFee #CivilLitigation #AttorneyClient #LawPractice #BillReid
May 18, 2026 at 2:31 AM
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Abrego Garcia turns the tables: did the Govt conspire against HIM?

A-G's lawyers say that most privilege assertions are bunk, even claiming the Crime-Fraud exception 👀 applies to some withheld communications between agencies.

On 6/4 Judge Xinis allowed A-G to seek sanctions for Discovery failures.
[Pt 1; Pt 2 to follow] 3. Crime-Fraud Exception Finally, there is sufficient evidence for the Court to apply the crime-fraud exception to vitiate the attorney-client/work product privilege. It is well-established that both “[t]he attorneyclient and work-product privileges are lost . . . when a client gives information to the attorneys for the purpose of committing or furthering a crime or fraud.” In re Grand Jury Proc., 102 F.3d 748, 750–51 (4th Cir. 1996). The “crime-fraud” exception applies broadly, including to materials furthering “misconduct fundamentally inconsistent with the basic premises of the adversary system.” In re Sealed Case, 676 F.2d 793, 812 (D.C. Cir. 1982); see also Cleveland Hair Clinic, Inc. v. Puig, 968 F.Supp. 1227, 1241 (N.D. Ill. 1996) (applying the crime-fraud exception where attorneys engaged in “deceptive conduct” and “bad faith litigation conduct” “violative of Rules 11 and 37”); In re St. Johnsbury Trucking Co., 184 B.R. 446, 455–56 (Bankr. D. Vt. 1995) (“[N]ot just technical crimes or frauds are excluded from the attorney-client privilege.”). Defendants appear to be relying on overbroad privilege invocations in order to shield evidence that Defendants and their attorneys have actively worked to defy, not comply with, this Court’s, the Fourth Circuit’s, and the Supreme Court’s orders. Their repeated public statements have made this clear. See, e.g., Eric Cortellessa & Sam Jacobs, Read the Full Transcript of Donald Trump's ‘100 Days’ Interview With TIME, TIME (Apr. 25, 2025) (asked if he would ask the President of El Salvador to return Abrego Garcia, the President stating “I haven’t asked him positively” “because I haven’t been asked to ask him by my attorneys”); Rebecca Beitsch, Bondi Says Mistakenly Deported Man ‘Not Coming Back to Our Country’, The Hill (Apr. 16, 2025) (Attorney General Pam Bondi stating that Abrego Garcia “is not coming back to our country” ...
June 7, 2025 at 1:14 PM
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EFTA01909656 | EFTA01909656 To: From: Sent: Jeffrey Epsteinfleeyacation©gmail.com] Tancredi Marchiolo Thur 1/24/2013 2:08:47 PM If vaiva comes tue/wed can she stay at yours? ************* **** ***** ******* ****** * **************************** ***************** The information contained in this communication is confidential, may be attorneyclient privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of Bremner Capital Management. Please note that this email is not and is not intended to be construed as an offer or an invitation to treat. All details commercial, legal, or otherwise are strictly subject to negotiation. Bremner Capital Management and its affiliates do not assume any liability for the content of this email, or make any representation or warranties, as to the accuracy or completeness of any information. Unauthorised use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to investor-relations@bremnercapital.com, and destroy this communication and all copies thereof, including all attachments. Bremner Capital Management reserves the right to retain all messages. Messages are protected and accessed only in legally justified cases. copyright - all rights reserved EFTA_R1_00345213 EFTA01909656 Epstein Web iOS app on the App Store.
March 14, 2026 at 6:07 PM
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EFTA02009518 | EFTA02009531 ******* ******* ******* ******* ******* •t• The informat ion containe d in this commun ication is confiden tial, may be attorneyclient privilege d, may constitut e inside informat ion, and is intended only for the use of the addresse e. It is the property of Jeffrey Epstein Unautho rized use, disclosu re or copying of this commun ication EFTA_R1_00510398 EFTA02009531
March 18, 2026 at 7:30 PM
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EFTA01994394 | EFTA01994394 Subject Re: Re: Sorry just got this , toomant people Sorry for all the typos .Sent from my iPhone On May 2, 2011, at 10:36 PM, idnakinaneyaholcom wrote: Should I come tonight? Sent via BlackBerry from T-Mo • • • < vacation©gmall.com>Date: Mon, 2 May 2011 13:02:50> Subject: 0.00To: I *********************************************************** big katya at 4? The information contained in this communication is confidential, may be attorneyclient privileged, may constitute inside information, and is intended only for EFTA_R1_00488373 EFTA01994394
March 17, 2026 at 11:30 PM
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EFTA02156875 | EFTA02156875 To: From: Sent: Subject: Tancredi Marchiolo Tue 10/23/2012 7:40:27 AM Re: Jeffrey Epstein Hi I'll'. i told her to send it to you, its better if she does it as she has a work relationship with a regulated entity of which i am a shareholder. Pls let me know how things move. **IFIttitt*Itt*IFIllt*Ick**k******************************41.**. ****** Ill!**k**************** ***It The information contained in this communication is confidential, may be attorneyclient privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of Bremner Capital Management. Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by email to tmarchiolo@bremnercapital.com, and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved On 22 Oct 2012, at 13:18, wrote: > Hello Tancredi. Might you be able to pass along phone contact information for Vaiva as Jeffrey had requested? > Thank you so much, •> Assistant to Jeffrey Epstein • > Sent from my iPhone EFTA_R1_00826505 EFTA02156875
March 30, 2026 at 5:48 AM
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Why Hidden Facts Hurt Your Case

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#LegalStrategy #CasePreparation #ClientHonesty #Deposition #PersonalInjuryLaw #LitigationProcess #AttorneyClient #ChantelleAmeli #MarkAmeli
July 10, 2026 at 3:32 PM
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Why Full Honesty Matters In Cases

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July 6, 2026 at 3:31 PM
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Parts 1-2/2 — EFTA01121386.jpg
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EFTA01121370 | EFTA01121386 10. Information and Inspection Rights; Other Covenants. 10.1 Information Rights. (a) So long as an Investor owns any shares of Senior Preferred, the Company will, upon request by an Investor, provide to such Investor, as soon as practicable after the end of each fiscal year, and in any event within one hundred fifty (150) days thereafter, an audited balance sheet of the Company, as at the end of such fiscal year, and an audited statement of income and statement of cash flows of the Company for such fiscal year, all prepared in accordance with generally accepted accounting principles; and (b) The Company will, upon request by a Major Investor, provide to such Major Investor, as soon as practicable after the end of each fiscal quarter, and in any event within forty-five (45) days thereafter, an unaudited balance sheet of the Company, as at the end of such quarter, and an unaudited statement of income and statement of cash flows of the Company for such quarter, each prepared in accordance with generally accepted accounting principles: quarterly summaries of the Company's capitalization on a fully diluted basis; (ii) at least thirty (30) days prior to the end of each fiscal year, an annual budget for the Company for the coming fiscal year; and (iii) comparison of the results reported in financial statements of the Company for any fiscal year to corresponding items in the applicable annual budget and the preceding year's financial statements. 10.2 Inspection Rights. The Company shall permit the Major Investors, at such Major Investor's expense, to visit and inspect the Company's properties, to examine its books of account and records and to discuss the Company's affairs, finances and accounts with its officers, all at such reasonable times as may be requested by such Major Investor; provided, however, that the Company shall not be obligated pursuant to this Section 10.2 to provide access to any information (a) that it reasonably considers to be a trade secret or similar confidential information or (b) if the Company believes in good faith that such exclusion is reasonably necessary to preserve attorneyclient privilege. 10.3 Assignment of Information and Inspection Rights. (a) The rights granted pursuant to Section 10. 1 may be transferred or assigned by an Investor only to a transferee of not less than shares of Senior Preferred (as adjusted for any stock dividends, combinations or splits with respect to such shares). (b) The rights granted pursuant to Section 10.2 may be transferred or assigned by a Major Investor only to a transferee who holds, following such transfer or assignment, shares of Senior Preferred (as adjusted for any stock together with its affiliates, at least dividends, combinations or splits with respect to such shares). I 7. EFTA01121386
May 10, 2026 at 3:30 AM
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EFTA01120045 | EFTA01120048 b. The Crime-Fraud Exception Epstein's objections should be overruled for a more fundamental reason: the attorneyclient privilege does not apply to any communication with an attorney for the purpose of aiding a plan to commit what the client knew was a crime or fraud. Fla. Stat. § 90.502(4)(a). The crimefraud exception "effectively eliminates the privileged character of an attorney-client communication." Butler, Pappas, Weihmuller, Katz, Craig, LLP v. Coral Reef of Key Biscayne Developers, Inc., 873 So. 2d 339, 342 (Fla. 3d DCA 2003). The crime-fraud exception can serve as a basis for requiring answers to interrogatories. Leithauser v. Harrison, 168 So. 2d 95, 98 (Fla. 2d DCA 1964). Epstein filed a baseless lawsuit against Edwards in order to avoid compensatory and punitive damage liability, to deter cooperation in the ongoing criminal investigations, and to intimidate his victims and their counsel into abandoning legitimate claims and/or resolving claims for substantially less than their just value. Thus, his retention of legal services assisted Epstein in committing, or attempting to commit, the crimes of extortion, obstruction of justice, and witness tampering.' The party invoking the crime-fraud exception has the initial burden of presenting prima facie evidence that the exception applies. BNP Paribas v. Wynne, 967 So. 2d 1065, 1067 (Fla. 4th DCA 2007) (citing American Tobacco Co. v. State, 697 So. 2d 1249, 1256 (Fla. 4th DCA 1997). The burden then shifts to the party asserting privilege to show, by a preponderance of the evidence, that there is a reasonable explanation for the communication. Id. ' It is immaterial whether the lawyer knows that the client intends to commit a crime or perpetrate a fraud. BNP Paribas v. Wyme, 967 So. 2d 1065, 1067 (Ha. 4th DCA 2007). 4 EFTA01120048
May 10, 2026 at 2:23 AM
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EFTA01111883 | EFTA01111892 Case 1:15-cv-07433-RWS Document 79-2 Filed 04/04/16 Page 10 of 18 Document Request No. 16: All computers, hard drives or copies thereof for all computers in operation between 1999- 2002. RESPONSE: Ms. Maxwell objects to this Request on the grounds that it is overly broad, unduly burdensome and/or propounded for the improper purpose of annoying or harassing Ms. Maxwell. Ms. Maxwell further objects to this Request on the grounds that it calls for the production of copies of computers or hard drives that contain documents, media and other data that are irrelevant to this action and not reasonably calculated to lead to the discovery of admissible evidence. Ms. Maxwell further objects to this Request to the extent it implicates her right to privacy. Gateway Logistics, Inc. v. Smay, 302 P.3d 235 (Colo. 2013); Fed. R. Evid. 501. Subject to and without waiving the above objections, Ms. Maxwell has been unable to locate any computers, hard-drives or copies of any computers responsive to this Request. Document Request No. 17: All documents relating to communications with you and Ross Gow from 2005 — Present. RESPONSE: Ms. Maxwell objects to this Request on the grounds that it is overly broad, unduly burdensome and/or propounded for the improper purpose of annoying or harassing Ms. Maxwell. Ms. Maxwell further objects to this Request to the extent that it calls for the production of documents that are irrelevant to this action and not reasonably calculated to lead to the discovery of admissible evidence. Ms. Maxwell also objects to this request to the extent it seeks documents or information protected by the attorney/client privilege, the common interest privilege, the work-product doctrine, or any other applicable privilege. Subject to and without waiving the above objections, Ms. Maxwell is withholding documents responsive to this Request that are outside of the Relevant Periods defined in paragraph 15, supra as well as the period of January I, 2011 to December 31, 2011, and also withholding documents within the Relevant Periods that are privileged. Ms. Maxwell has been unable to locate any non-privileged documents that are within such Relevant Periods. Document Request No. 18: All video tapes. audio to s photographs or any other print or electronic media relating t RESPONSE: Ms. Maxwell objects to this Request to the extent it calls for attorneyclient communications and attorney work product. Ms. Maxwell also objects to this Request to the extent it calls for video tapes, audio tapes, photographs or any other print or electronic media relating t that exists within the public domain, the intemet or in public court records and which are equally available to both parties and can be obtained from some other source that is more convenient, less burdensome, and less expensive. Subject to and without waiving the above objections, Ms. Maxwell has been unable to locate any documents responsive to this Request. 9 EFTA01111892 Epstein Web iOS app on the App Store.
May 9, 2026 at 8:06 PM
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EFTA01111883 | EFTA01111891 Case 1:15-cv-07433-RWS Document 79-2 Filed 04/04/16 Page 9 of 18 RESPONSE: Ms. Maxwell objects to this Request as vague and confusing. Ms. Maxwell objects to this Request to the extent it requests documents subject to either the attorneyclient or work product privileges. Ms. Maxwell objects to this Request on the grounds that it is overly broad, unduly burdensome and/or propounded for the improper purpose of annoying or harassing Ms. Maxwell. Ms. Maxwell further objects to this Request on the grounds that it calls for the production of documents that are irrelevant to this action and not reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the above objections, Ms. Maxwell has been unable to locate any documents responsive to this Request. Document Request No. 14: All documents relating to travel of any female under the age of 18 from the period of 1999 — present. RESPONSE: Ms. Maxwell objects to this Request on the grounds that it is overly broad, unduly burdensome and/or propounded for the improper purpose of annoying or harassing Ms. Maxwell. Ms. Maxwell further objects to this Request on the grounds that it calls for the production of documents that are irrelevant to this action and not reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving the above objections, Ms. Maxwell has been unable to locate any documents responsive to this Request. Document Request No. 15: All video tapes, audio tapes, photographs or any other print or electronic media taken at a time when you were in Jeffrey Epstein's company or inside any of his residences or aircraft. RESPONSE: Ms. Maxwell objects to this Request on the grounds that it is overly broad, unduly burdensome and/or propounded for the improper purpose of annoying or harassing Ms. Maxwell. Ms. Maxwell further objects to this Request on the grounds that it calls for the production of documents that are irrelevant to this action and not reasonably calculated to lead to the discovery of admissible evidence. Ms. Maxwell further objects to this Request to the extent it implicates her right to privacy. Gateway Logistics, Inc. v. &nay, 302 P.3d 235 (Colo. 2013); Fed. R. Evid. 501. Subject to and without waiving the above objections, Ms. Maxwell has been unable to locate any documents responsive to this Request that are within the Relevant Periods described in paragraph 15, supra. Ms. Maxwell is withholding production of documents outside of such Relevant Periods. 8 EFTA01111891
May 9, 2026 at 8:06 PM
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EFTA01107056 | EFTA01107072 10. Information and Inspection Rights; Other Covenants. 10.1 Information Rights. (a) So long as an Investor owns any shares of Senior Preferred, the Company will, upon request by an Investor, provide to such Investor, as soon as practicable after the end of each fiscal year, and in any event within one hundred fifty (150) days thereafter, an audited balance sheet of the Company, as at the end of such fiscal year, and an audited statement of income and statement of cash flows of the Company for such fiscal year, all prepared in accordance with generally accepted accounting principles; and (b) The Company will, upon request by a Major Investor, provide to such Major Investor, as soon as practicable after the end of each fiscal quarter, and in any event within forty-five (45) days thereafter, an unaudited balance sheet of the Company, as at the end of such quarter, and an unaudited statement of income and statement of cash flows of the Company for such quarter, each prepared in accordance with generally accepted accounting principles: (i) quarterly summaries of the Company's capitalization on a fully diluted basis; (ii) at least thirty (30) days prior to the end of each fiscal year, an annual budget for the Company for the coming fiscal year; and (iii) comparison of the results reported in financial statements of the Company for any fiscal year to corresponding items in the applicable annual budget and the preceding year's financial statements. 10.2 Inspection Rights. The Company shall permit the Major Investors, at such Major Investor's expense, to visit and inspect the Company's properties, to examine its books of account and records and to discuss the Company's affairs, finances and accounts with its officers, all at such reasonable times as may be requested by such Major Investor; provided, however, that the Company shall not be obligated pursuant to this Section 10.2 to provide access to any information (a) that it reasonably considers to be a trade secret or similar confidential information or (b) if the Company believes in good faith that such exclusion is reasonably necessary to preserve attorneyclient privilege. 10.3 Assignment of Information and Inspection Rights. (a) The rights granted pursuant to Section 10.1 may be transferred or assigned by an Investor only to a transferee of not less than 100,000 shares of Senior Preferred (as adjusted for any stock dividends, combinations or splits with respect to such shares). (b) The rights granted pursuant to Section 10.2 may be transferred or assigned by a Major Investor only to a transferee who holds, following such transfer or assignment, together with its affiliates, at least 2,000,000 shares of Senior Preferred (as adjusted for any stock dividends, combinations or splits with respect to such shares). 17. 1222099 96/SF EFTA01107072
May 9, 2026 at 4:22 PM
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EFTA01097606 | EFTA01097608 Filed, Frank, Harris, Skiver & Jacobson LIP Mr. Peter Altenbach Confidential Pursuant to 17 CFR § 200.83 December 20, 2007 Page 3 Please be advised that certain information has been redacted from some of the above referenced e-mails messages, on the basis that the redacted information is subject to the attorneyclient privilege and/or attorney work product doctrine. Every redacted document has been marked with the word "REDACTED" in the place(s) where the information has been redacted. With the exception of redacted e-mail messages, which arc being produced in TIFF image form only, these c-mail messages arc being produced to the Staff as both TIFF images and as native files with a Concordance load file. As previously noted, in some instances native files could not be converted into TIFF images. For the Staffs convenience, we are providing those files in native format, which can be found on the hard drive in the folders labeled "DBZCO EX021," and "DBZCOPR EX010." We will continue to produce e-mail messages concerning the 8 Investments, as well as 'electronic messages for the individuals identified by the stag on a rolling basis. Please feel free to contact me with any questions you may have. This production is not intended to, and does not, waive any applicable privilege or protection, including the attorney-client privilege or work product protection. If any information that would be protected by the attorney-client privilege or work product doctrine was produced, such production was inadvertent and was not intended to be a waiver of any applicable privilege or protection and we respectfully request the return of such privileged material. On behalf of our client, we hereby claim that all materials provided to the Staff during the course of its investigation, including this letter (Bates-stamped DBZ 0036142 - DBZ 0036145), all documents produced, all CDs, DVDs, and hard drives produced and the information contained therein, and all testimony provided by our client, are entitled to confidential treatment pursuant to the Freedom of Information Act Each document has been appropriately labeled to indicate the intention to maintain the confidential status of the enclosed materials. This claim of confidentiality shall continue indefinitely unless we advise you otherwise. Should the Commission receive any request for these documents pursuant to the Freedom of Information Act or pursuant to a third-party subpoena or document demand (from a party other than a federal, state, local or foreign law enforcement agency, or a governmental entity, or a self-regulatory organization), we expect that we will be given notice and an opportunity to object to such disclosure. In such event, we request that the Staff telephone the undersigned rather than rely upon the United States mail for such notice. We request the Staff also provide a written copy of such notice to our client, addressed as follows: Lawrence Cutler, Chief Compliance Officer and Chief Operating Officer, D.B. Zwim & Co., L.P., 745 Fifth Avenue - 18th Floor, New York, NY Confidential Treatment Requested by Fried Frank Harris Shrivcr & Jacobson LLP DBZ 0036144 EFTA01097608
May 9, 2026 at 9:14 AM
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EFTA01079793 | EFTA01079850 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 58 of 70 Privilege(s) Asserted Work Product Investigative Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation Work product Victims' Objections Anticipation of Litigation; Ordinary Government Communication; No AttorneyClient Relationship; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue Bates Range Thru P-013621 Description handwritten notes by A. Marie Villafafia Suppl. Box #3 P-013622 Thru P-013643 File folder entitled "Research Re Possible containing attorney Misdemeanors" research Suppl. Box #3 P-013644 Thru P-013653 File folder entitled "Notes Re Plea Attorney-Client Privilege Work Product Negotiations" containing 9/17/07 e-mail Deliberative Process from A. Marie Villafafia to J. Richards, N. Investigative privilege Kuyrkendall re status update; undated and typed handwritten notes by A. Marie Also contains information Villafafia re items to be completed on subject to privacy rights of victims who are not case, strength of case, victim interviews, parties to this litigation guidelines summary of evidence, calculations Attorney-Client Privilege File folder entitled "Plea Agreement Work Product Drafts" containing several draft plea agreements some with handwritten notes Deliberative Process by A. Marie Villafafia; copies of draft non-prosecution agreement some with handwritten notes by A. Marie Villafafia; copy of a draft Information Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Litigation; Ordinary Anticipation of Government Communication; No AttorneyClient Relationship; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Waiver Attorney-Client Privilege Work Product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Suppl. Box #3 P-013654 Thru P-013745 Suppl. Box #3 P-0013747 File folder entitled "Draft NonAgreements" containing Prosecution Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Government Litigation; Ordinary Attorney-Client Communication; No Relationship; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue Page 57 of 69 EFTA01079850
May 9, 2026 at 12:11 AM
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EFTA01079793 | EFTA01079843 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 51 of 70 Bates Range P-013337 Description responding to J. Leflcowitz's letter Privilege(s) Asserted Work Product Suppl. Box #3 P-013338 Thru 013341 File folder entitled "12/6/07 Sloman to Lefkowitz" containing 12/5/07 faxed letter w/ cover sheet from K. Starr and J. Lefkowitz to A. Acosta Suppl. Box #3 P-013342 Thru P-013350 File folder entitled "12/05/07 Starr to Acosta" containing drafts of 11/30/07 letters from A. Acosta to K. Starr and from J. Sloman to J. Leflcowitz re performance and victim notification with handwritten notes and edits by A. Marie Villafafia [Not considered privileged. Will be produced to opposing counsel upon lifting of stay] Attorney-Client Privilege Work Product Deliberative Process Suppl. Box #3 File folder entitled "12/21/07 Lefkowitz Acosta" containing handwritten notes by P-13351 12/21/07 letter A. Marie Villafafia, Thru P-013361 from J. Leflcowitz to A. Acosta re performance of NPA and appeal to handwritten Washington with attorney notes Suppl. Box #3 File folder labeled "12/26/07 Lefkowitz P-013362 to Acosta" containing 2 copies of draft letter from A. Acosta to J. Lefkowitz Thru P-013366 (with 12/28/07 fax header) Attorney-Client Privilege Work Product kr from Attorney-Client Privilege Suppl. Box #3 File folder labeled "Draft Attorney-Client Privilege Work Product Deliberative Process Victims' Objections Communication; No Attorney-Client Relationship; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue N/A Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Crime-Fraud-Misconduct; Factual Materials; Not in Anticipation of Government Litigation; Ordinary Attorney-Client Communication; No Relationship; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Crime-Fraud-Misconduct; Not in Anticipation of Litigation; Ordinary Government Communication; No AttorneyClient Relationship; Claims Against Public Need; Factual Prosecutor; Overriding Materials; Attorney Conduct at Issue Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Crime-Fraud-Misconduct; Not in Anticipation of Litigation; Ordinary Government Communication; No AttorneyClient Relationship; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue Inadequate Log; No Factual Underpinnings; Page 50 of 69 EFTA01079843
May 9, 2026 at 12:11 AM
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EFTA01079793 | EFTA01079842 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 50 of 70 Privilege(s) Asserted Work Product Victims' Objections Government Communication; No AttorneyClient Relationship; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue; Waiver File folder entitled "6/25/07 Lefcourt to Sloman & Lourie containing 6/25/07 letter (with handwritten notes by A. Marie Villafafia) from G. Lefcourt to J. Sloman, M. Menchel, A. Lourie, A. Marie Villafafia addressing reasons for not prosecuting Epstein; handwritten outline by A. Marie Villafafia of possible response to letter Suppl. Box #3 File folder entitled "9/17/07 Villafafia Lefkowitz containing 9/17/07 e-mail from P-013326 A. Marie Villafafia to R. Garcia, A. Lourie Thru P-013329 and from R. Garcia to A. Marie Villafafia concerning status of plea negotiations Attorney-Client Privilege Work Product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Crime-Fraud-Misconduct; Not in Anticipation of Litigation; Ordinary Government Communication; No AttorneyClient Relationship Attorney-Client Privilege Work Product Suppl. Box #3 File folder entitled "11/8/07 Lefkowitz Sloman" containing 11/8/07 letter from P-013330 J. Lefkowitz re issues arising during Thru pendency of matter with attorney P-013333 handwritten notes Attorney-Client Privilege Work Product Suppl. Box #3 File folder entitled "11/13/07 Sloman to Lefkowitz (was this sent?)" containing P-013334 draft 11/13/07 letter from J. Sloman Thru Attorney-Client Privilege Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Ordinary Government Communication; No Attorney-Client Relationship; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Ordinary Government Communication; No Attorney-Client Relationship; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Ordinary Government Bates Range P-0133303 Description proposed letter to J. Lefkowitz; 5/22/07 email from A. Lourie to M. Menchel, J. Sloman, A. Marie Villafafia re meeting with G. Lefcourt with attached email from G. Lefcourt re solicitation for meetings Suppl. Box #3 P-013304 Thru P-013325 Page 49 of 69 EFTA01079842
May 9, 2026 at 12:11 AM
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EFTA01079793 | EFTA01079797 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 5 of 70 Bates Range Box #1 P-000804 thru P-000854 Box #1 P-000855 thru P-000937 Description File folder entitled "DTG Operations/Dollar Rent-a-Car" containing subpoena and responsive documents Privilege(s) Asserted 6(e) Contains documents and information subject to investigative privilege Also contains documents and information subject to privacy rights of victims who are not parties to this litigation File folder entitled "JP Morgan Chase" 6(e) containing subpoena, correspondence, and Contains documents and responsive documents information subject to investigative privilege Box #1 P-000938 thru P-000947 File folder entitled 'Washington Mutual" containing subpoena, correspondence, and responsive documents 6(e) Contains documents and information subject to investigative privilege Box #1 P-000948 thru P-000982 File folder entitled "Computer Search &" containing legal research on computer search and handwritten notes on indictment preparation Work Product Attorney-Client Contains information subject to investigative privilege. Also contains information subject to privacy rights of victims who are not parties to this litigation Victims' Objections Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable; Redaction; No Assertion by Victims Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRAauthorized release; Material Severable Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation; Improper Invocation; Overriding Need; Factual Materials; Court Authorized Under 6(e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRAauthorized release; Material Severable Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Factual Materials; Not in Anticipation of Litigation; Ordinary Government Communication; No AttorneyClient Relationship; Improper Invocation; Overriding Need; Claims Against Public Prosecutor; Attorney Conduct at Issue; Redaction; No Assertion by Victims Page 4 of 69 EFTA01079797
May 9, 2026 at 12:09 AM
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EFTA00883258 | EFTA00883265 Date: Wed, Jul 26, 2017 at 3:32 PM Subject: please note The information contained in this communication is confidential, may be attorneyclient privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of JEE Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to jeevacation@gmail.com, and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved please note The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of JEE EFTA00883265 Epstein Web iOS app on the App Store.
May 7, 2026 at 1:11 PM
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EFTA00874967 | EFTA00874977 to jeevacation@gmail.cotn, and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved please note The information contained in this communication is confidential, may be attorneyclient privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of JEE Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to jeevacation@gmail.com, and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved please note The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of JEE EFTA00874977 Epstein Web iOS app on the App Store.
May 7, 2026 at 10:36 AM
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EFTA00868345 | EFTA00868359 attachments. copyright all rights reserved please note The information contained in this communication is confidential, may be attorneyclient privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of JEE Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to jeevacation@gmail.com, and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved please note The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of JEE Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this EFTA00868359 Epstein Web iOS app on the App Store.
May 7, 2026 at 8:49 AM
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EFTA00832883 | EFTA00832936 please note The information contained in this communication is confidential, may be attorneyclient privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of JEE Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to jeevacation@gmail.com, and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved please note The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of JEE Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to jeevacation@gmail.com, and destroy this communication and all copies thereof, EFTA00832936
May 6, 2026 at 10:36 PM
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EFTA00832883 | EFTA00832934 n@ ail corn, and destroy this communi cation and all copies thereof, including all attachmen ts. copyright -all rights reserved please note The information contained in this communication is confidential, may be attorneyclient privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of JEE Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to EFTA00832934
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EFTA00832883 | EFTA00832933 on contained in this communi cation is confidenti al, may be attorneyclient privileged , may constitute inside informati on, and is intended only for the use of the addressee. It is the property of JEE Unauthori zed use, disclosure or copying of this communi cation or any part thereof is strictly prohibited and may be unlawful. If you have received this communi cation in error, please notify us immediat ely by return email or by e-mail to jeevacatio EFTA00832933 Epstein Web iOS app on the App Store.
May 6, 2026 at 10:35 PM
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EFTA00806915 | EFTA00806947 12. Equally consistent with the allegations in the press and in the Razorback Complaint that the Epstein Cases were being deliberately misused for purposes unrelated to the litigation in order to lure investors into the Ponzi Scheme is the fact that on July 24,2009, Edwards filed a two hundred thirty-four (234) page, one fifty-six (156) count federal complaint against me on behalf of a plaintiff, LM, for whom Edwards was already prosecuting a case against me in state court involving the same matters alleged in the federal complaint. The complaint was filed in federal court, but was never served on me or prosecuted, leading me to conclude that the only reason it was filed was to enhance the case files shown at the offices of RRA to potential investors in the Ponzi Scheme. 13. Also while a partner at RRA, Edwards filed a motion in Federal court in which he requested that the court order me to post a fifteen million dollar bond in the Jane Doe case. This case, according to the Razorback Complaint, was being touted at that same time to investors in the Ponzi Scheme. In connection with that motion, Edwards filed papers discussing my net worth and filed supplemental papers purporting to list in great detail my vehicles, planes and other items of substantial value, all at a time when, according to the accounts in the press, the Information and the Razorback Complaint, the Ponzi Scheme was unraveling and the need for new investors in the Ponzi Scheme was becoming urgent. The court rejected the Motion, calling it "devoid of evidence." (15th Jud. Cir. Case No. 50-2009-CA-040800-XXXX-MB DE-931 ¶¶ 5-13.) III. EDWARDS' DEPOSITION TESTIMONY A. Edwards Deposition—March 23, 2010 Edwards testified as follows: Q: Did he ever call you to communicate with you, call you either by phone, video conference, in any fashion to discuss any aspect of the cases that you had against Jeffrey Epstein? A: He has communicated about various, about legal issues related to the case as well as commented about the case to me on very few occasions but I would say less than three times. (Tr. at 112:7-16.) Q: All right. Do you remember a third occasion that he spoke to you regarding Epstein related occasion, cases? A: Anything else that he ever spoke with me about related to Epstein related issues is attorneyclient and work-product privileged information that I am not going to divulge. (Tr. at 116:21-117:3.) Q: All right. And when you got into the office, Mr. Rothstein was there? 33 EFTA00806947 Epstein Web iOS app on the App Store.
May 6, 2026 at 4:55 PM